United States. Congress. House. Committee on the J.

In-state plaintiff diversity jurisdiction : hearing before the Subcommittee on Intellectual Property and Judicial Administration of the Committee on the Judiciary, House of Representatives, One Hundred Third Congress, second session, on H.R. 4357 (section 305) ... and H.R. 4446 ... May 26, 1994 online

. (page 1 of 10)
Online LibraryUnited States. Congress. House. Committee on the JIn-state plaintiff diversity jurisdiction : hearing before the Subcommittee on Intellectual Property and Judicial Administration of the Committee on the Judiciary, House of Representatives, One Hundred Third Congress, second session, on H.R. 4357 (section 305) ... and H.R. 4446 ... May 26, 1994 → online text (page 1 of 10)
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IN-STATE PLAINTIFF DIVERSITY JURISDICTION



HEARING



BEFORE THE



SUBCOMMITTEE ON INTELLECTUAL PROPERTY
AND JUDICAL ADMINISTRATION

OF THE

COMMITTEE ON THE JUDICIARY
HOUSE OF REPRESENTATIVES

ONE HUNDRED THIRD CONGRESS

SECOND SESSION
ON

H.R 4357 (Section 305)

FEDERAL COURTS IMPROVEMENT ACT OF 1994
(IN-STATE PLAINTIFF DIVERSITY JURISDICTION)

AND

H.R 4446

IN-STATE PLAINTIFF DIVERSITY JURISDICTION



GOV'T.



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52




HAMPDEN LAW LIBRARY

Printed for the use of the Commilfc



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6Q^F0v#ipy«LICLI3RARY

GOVERf MENT DOCUMENTS DEPARTMENT



83-577 CC



U.S. GOVERNMENT PRINTING OFFICE
WASHINGTON : 1994



For sale by the U.S. Government Printing Office
Superintendent of Documents, Congressional Sales Office. Washington. DC 20402
ISBN 0-16-046190-1



\) H . 3 S''-t / i 103, /S O

INSTATE PLAINTIfT DIVERSITY JURISDICTION



HEARING

BEFORE THE

SUBCOMMITTEE ON INTELLECTUAL PROPERTY
AND JUDICAL ADMINISTRATION

OF THE

COMMITTEE ON THE JUDICIAEY
HOUSE OF REPRESENTATIVES

ONE HUNDRED THIRD CONGRESS

SECOND SESSION
ON

H.R 4357 (Section 305)

FEDERAL COURTS IMPROVEMENT ACT OF 1994
(IN-STATE PLAINTIFF DIVERSITY JURISDICTION)

AND

H.R 4446

IN-STATE PLAINTIFF DIVERSITY JURISDICTION



GOV'T.



iviAv ^b, iyy4



DEPOSngLWal No.



52



\a'




<S



HAMPDEN LAW LIBRARY

Printed for the use of the Commijl e^^ g?i^ Qy^i^^ifc^ | \(\ LIBRARY

GOVERf.MENT DOCUMENTS DEPARTMENT



83-577 CC



U.S. GOVERNMENT PRINTING OFFICE
WASHINGTON : 1994



For sale by the U.S. Goveniment Printing Office
Supenntendent of Documents, Congressional Sales Office, Washington. DC 20402
ISBN 0-16-046190-1



COMMITTEE ON THE JUDICIARY



JACK BROOKS,



DON EDWARDS, California
JOHN CONYERS, JR., Michigan
ROMANO L. MAZZOLI, Kentucky
WILLIAM J. HUGHES, New Jersey
MIKE SYNAR, Oklahoma
PATRICIA SCHROEDER, Colorado
DAN GLICKMAN, Kansas
BARNEY FRANK, Massachusetts
CHARLES E. SCHUMER, New York
HOWARD L. BERMAN, California
RICK BOUCHER, Virginia
JOHN BRYANT, Texas
GEORGE E. SANGMEISTER, Illinois
CRAIG A. WASHINGTON, Texas
JACK REED, Rhode Island
JERROLD NADLER, New York
ROBERT C. SCOTT, Virginia
DAVID MANN, Ohio
MELVIN L. WATT, North Carolina
XAVIER BECERRA, California



Texas, Chairman

HAMILTON FISH, JR., New York
CARLOS J. MOORHEAD, California
HENRY J. HYDE, Illinois
F. JAMES SENSENBRENNER, JR.,

Wisconsin
BILL McCOLLUM, Florida
GEORGE W. GEKAS, Pennsylvania
HOWARD COBLE, North Carolina
LAMAR S. SMITH, Texas
STEVEN SCHIFF, New Mexico
JIM RAMSTAD, Minnesota
ELTON GALLEGLY, California
CHARLES T. CANADY, Florida
BOB INGLIS, South Carolina
BOB GOODLATTE, Virginia



Jonathan R. YaROWSKY, General Counsel

Robert A. LEMBO, Counsel / Administrator

ALAN F. Coffey, Jr., Minority Chief Counsel



SUBCOMMITTEE ON INTELLECTUAL PROPERTY AND JUDICIAL ADMINISTRATION



WILLIAM J

C- DON EDWARDS, California
JOHN CONYERS, JR., Michigan
ROMANO L. MAZZOLI, Kentucky
MIKE SYNAR, Oklahoma
BARNEY FRANK, Massachusetts
HOWARD L. BERMAN, California
JACK REED, Rhode Island
XAVIER BECERRA, California



HUGHES, New Jersey, Chairman

CARLOS J. MOORHEAD, Cahfomia
HOWARD COBLE, North Carolina
HAMILTON FISH, JR., New York
F. JAMES SENSENBRENNER, JR.,
Wisconsin
»BILL McCOLLUM, Honda
STEVEN SCHIFF, New Mexico



Hayden W. Gregory, Counsel

Edward O'ConnELL, Assistant Counsel

William F. Patry, Assistant Counsel

JaRILYN Dupont, Assistant Counsel

Thomas E. MOONEY, Minority Counsel

Joseph V.' Wolfe, Minority Counsel



Vf



ym-it^



08 L



(II)



CONTENTS



HEARING DATE



Page

May 26, 1994 1

TEXTS OF BILLS

H.R. 4357 (section 305) 3

H.R. 4446 5

OPENING STATEMENT

Hughes, Hon. William J., a Representative in Congress from the State of
New Jersey, and chairman. Subcommittee on Intellectual Property and
Judicial Administration 1

WITNESSES

Dolin, Mitchell F., co-chair. Federal Legislation Committee, American Bar
Association's section of litigation 46

Frank, John P., senior partner, Lewis & Roca law firm, Phoenix, AZ, on

behalf of the Arizona State Bar Association 33

Marcus, Stanley, judge. Southern District of Florida, and Chairman, Judicial
Conference Committee on Federal-State Jurisdiction, and Chairman, Ad
Hoc Committee on Gender-Based Violence 8

LETTERS, STATEMENTS, ETC., SUBMITTED FOR THE HEARING

Dolin, Mitchell F., co-chair. Federal Legislation Committee, American Bar

Association's section of litigation: Prepared statement 48

Frank, John P., senior partner, Lewis & Roca law firm. Phoenix, AZ, on

behalf of the Arizona State Bar Association: Prepared statement 37

Marcus, Stanley, judge. Southern District of Florida, and Chairman, Judicial
Conference Committee on Federal-State Jurisdiction, and Chairman, Ad
Hoc Committee on Gender-Based Violence:

Prepared statement 10

Statement of the Conference of Chief Justices on H.R. 4446 28

APPENDIXES

Appendix 1. — Answers of Mitchell F". Dolin to written questions posed by

Chairman William J. Hughes, June 6, 1994 65

Appendix 2. — Letter from Barry J. Nace, president. Association of Trial Law-
yers of America, to Hon. William J. Hughes, chairman. Subcommittee on
Intellectual Property and Judicial Administration, May 26, 1994 76

Appendix 3. — "A Fresh Look at In-State Plaintiff Diversity Jurisdiction: Why
It Was Enacted and Why It Should Be Repealed," a report to the U.S.
Judicial Conference from the Conrmiittee on Federal-State Jurisdiction,
June 18, 1993 78



(HI)



IN-STATE PLAINTIFF DIVERSITY
JURISDICTION



THURSDAY, MAY 26, 1994

House of Representatives,
Subcommittee on Intellectual Property

and judicl\l administration,
Committee on the Judiciary,

Washington, DC.
The subcommittee met, pursuant to notice, at 10:20 a.m., in room
2237, Rayburn House Office Building, Hon. William J. Hughes
(chairman of the subcommittee) presiding.

Present: Representatives William J. Hughes, Don Edwards,
Carlos J. Moorhead, and Howard Coble.

Also present: Hayden Gregory, counsel; Edward O'Connell,
assistant counsel; Veronica Eligan, secretary; and Joseph Wolfe,
minority counsel.

OPENING STATEMENT OF CHAIRMAN HUGHES

Mr. Hughes. The Subcommittee on Intellectual Property and
Judicial Administration will come to order. Good morning and
welcome to this morning's hearing on the issue of in-State plaintiff
diversity jurisdiction. Diversity jurisdiction, generally, refers to the
jurisdiction of the Federal courts to hear matters involving non-
Federal law questions, when citizens of different States are oppos-
ing parties. Diversity jurisdiction is provided statutorily by 28
U.S.C. 1332. Both of the legislative proposals we will be discussing
today, H.R. 4446 and section 305 of H.R. 4357, would reduce the
basis for Federal court jurisdiction based solely on diversity of citi-
zenship. It would not eliminate it entirely.

Both proposals would eliminate that portion of the diversity
jurisdiction where a plaintiff is a citizen of the State in which he
files the action in Federal court. Neither of these provisions would
limit the applicability of removal by a defendant under 28 U.S.C.
1441(a). The difference between the proposals is that section 305
would eliminate diversity jurisdiction if any of the plaintiffs are
citizens of the State in which the suit is filed and H.R. 4446 would
eliminate it if all plaintiffs are citizens of the State in which the
suit is filed.

Historically the implementation of diversity jurisdiction by legis-
lation goes back to the First Congress which enacted the prede-
cessor of 28 U.S.C. 1332. At that time, the Congress, and before
them the draftees of the Constitution, had two fears about bias in
litigation in the State courts. The first was the possibility of bias
against out-of-State defendants who were litigants in State courts.

(1)



This initiated the right to removal by defendants. They also wor-
ried about a general bias in State courts against enforcement of
debts. This triggered the right for an in-State plaintiff to file in
Federal court.

Legislative efforts to reduce diversity jurisdiction in the Federal
courts has come to the fore at various intervals in recent years.
The Judicial Conference of the United States has long supported
total abolition of diversity iurisdiction, as well as measures short
of total elimination. In this Congress, the Conference is rec-
ommending section 305 of H.R. 4357, dealing with in-State plain-
tiffs suits, and section 101 of H.R. 4357, which would raise the ju-
risdictional minimum amount from $50,000 to $75,000 in diversity
cases. Today we will concentrate on the in-State plaintiff issues.

I have previously distributed to the members of the subcommit-
tee a 45-page paper submitted to the Judicial Conference by the
Committee on Federal-State Jurisdiction which documents their ra-
tionale for eliminating in-State plaintiff diversity iurisdiction. Their
conclusion was that, 'The historic justification of in-State plaintiff
jurisdiction has entirely evaporated." This combined with the
growth of the Federal caseload which included 16,033 new in-State
plaintiffs' diversity filings in 1992, suggests that we should seri-
ously consider curtailing this form of diversity jurisdiction.

I will look forward to hearing the excellent witnesses we have be-
fore us this morning.

[The bills, H.R. 4357 (section 305) and H.R. 4446, follow:]



103d congress
2d Session



H. R. 4357



To make improvements in the operation and administration of the Federal
courts, and for other purposes.



IN THE HOUSE OF REPRESENTATR^S

May 5, 1994

Mr. Hughes (for himself and Mr. Moorhead) (both by request) introduced

the following bill; which was referred to the Committee on the Judiciar>-



A BILL

To make improvements in the operation and administration
of the Federal courts, and for other purposes.

1 Be it enacted hy the Senate and House of Representa-

2 tives of the United States of America in Congress assembled,

3 SECTION 1. SHORT TITLE AND TABLE OF CONTENTS.

4 (a) Short Title. — This Act may be cited as the

5 "Federal Couits Improvement Act of 1994".



26

1 SEC. 305. ELIMINATION OF IN-STATE PLAINTIFF IN DIVER-

2 SITY JURISDICTION CASES.

3 Section 1332 of title 28, United States Code, is

4 amended by adding at the end the following new sub-

5 section:

6 "(e) The original jurisdiction of the district courts

7 otherwise conferred by this section may not be invoked if

8 any plaintiff joined in the complaint is a citizen of the

9 State in which is located the district court in which the

10 suit is filed. For purposes of this subsection only, the Dis-

1 1 trict of Wj'oming shall be deemed located solely uithin the

12 State of Wyoming. This subsection does not apply to or

13 limit the applicability of the right of removal under section

14 1441(a) of an action that would otherwise be within the

15 original jurisdiction of the district courts.".



•HR 4SS7 IH



103d congress
2d Session



H. R. 4446



To amend section 1332 of title 28, United States Code, to require that
the plaintiff in a diversity case not be a resident of the State in .vhich
the case is brought.



IN THE HOUSE OF REPRESENTATIVES

May 18, 1994

Mr. Hughes introduced the foUow-ing bill; which was referred to the

Committee on the Judiciary



A BILL

To amend section 1332 of title 28, United States Code,
to require that tlie plaintiff in a diversity case not be
a resident of the State in which the case is brought.

1 Be it enacted by the Senate and House of Representa-

2 tives of the United States ofAmenca in Congress assembled,

3 That section 1332 of title 28, United States Code is

4 amended by adding at the end the following:

5 "(e) The original jurisdiction of the district courts

6 othen\ase conferred by this section may not be invoked if

7 all plaintiffs joined in the complaint are citizens of the

8 State in which is located the district court in which the

9 suit is filed. For purposes of this subsection only —



2

1 "(1) the District of Wyoming shall be deemed

2 to be located solely within the State of Wyoming;

3 and

4 "(2) those portions of Yellowstone National

5 Park situated in Montana shall be deemed to be lo-

6 cated in the District of Montana; and

7 "(3) those portions of Yellowstone National

8 Park situated in Idaho shall be deemed to be located

9 in the District of Idaho.

10 This subsection does not apply to or limit the applicability

11 of the right of removal under section 1441(a) of an action

12 that would otherwise be Avithin the original jurisdiction of

13 the district courts.".

o



•HR 4446 IH



Mr. Hughes. The Chair recognizes the distinguished gentleman
from CaHfomia.

Mr. MooRHEAD. Thank you, Mr. Chairman. In a 1983 treatise ti-
tled, "Abolition of Diversity Jurisdiction, An Idea Whose Time Has
Come," our former colleague on this subcommittee, M. Caldwell
Butler of Virginia advocated the abolition of diversity jurisdiction
while one of our distinguished witnesses today, John Frank, argued
for its retention. In his article, Mr. Frank wrote that: "It is not
time for friends of the diversity jurisdiction to be smug. We do have
a conscientious duty to reexamine the situation. Federal filings are



up"



I would submit that there is a greater need today to assess the
need for diversity jurisdiction, given the strong trend in recent
years in Congress to federalize State issues, especially in the crimi-
nal justice area, from making carjacking a Federal crime, to giving
the Federal courts jurisdiction over fathers who slink on child sup-
port and then cross State lines.

Congress may be effectively shifting issues traditionally handled
by the State courts to the Federal courts. President Clinton is
scheduled to sign into law today legislation to make blocking abor-
tion clinics a Federal crime. And as Judge Marcus knows, there are
additional issues for the Federal courts in the omnibus crime bill
that is awaiting conference.

Many of you know that Congressman Waxman now has a bill
that has moved slightly, that would make it illegal to smoke in a
publicly used building, and would give any member of the public
the opportunity to bring charges in the Federal courts against the
landlord of the building.

My point is that the landscape for the Federal judiciary is chang-
ing dramatically, and it is timely to consider the role of diversity
jurisdiction in that context.

I commend the chairman for scheduling this hearing and look
forward to the testimony of our distinguished witnesses.

Mr. Edwards [presiding]. Thank you very much, Mr. Moorhead.

Our first witness today is the Honorable Stanley Marcus who is
a U.S. district judge for the Southern District of Florida.

Judge Marcus is also Chairman of the Committee on Federal-
State Jurisdiction for the Judicial Conference of the United States
and Chairman of the Ad Hoc Committee on Violence Against
Women for the Judicial Conference. That committee has been of
enormous help to us in writing that portion of the crime bill. We
are very grateful. Judge Marcus.

Judge Marcus has had a remarkable and varied career, having
served as the U.S. attorney for the Southern District of Florida, at-
torney in charge of the Department of Justice's strike force in De-
troit, MI, and an assistant U.S. attorney for the Eastern District
of New York. He also has been in the private practice of law in
New York.

Judge Marcus, we are delighted to have you here. Your written
statement will be made a part of the record, and you may proceed.



8

STATEMENT OF STANLEY MARCUS, JUDGE, SOUTHERN DIS-
TRICT OF FLORIDA, AND CHAIRMAN, JUDICIAL CON-
FERENCE COMMITTEE ON FEDERAL-STATE JURISDICTION,
AND CHAIRMAN, AD HOC COMMITTEE ON GENDER-BASED
VIOLENCE

Judge Marcus. Thank you very much Congressman Edwards,
Mr. Chairman. I am privileged to be invited to be here today to
share with the subcommittee some of the views of the Judicial Con-
ference of the United States on this important subject.

I think this subcommittee and its members should be com-
mended for conducting hearings on this subject. It could not be,
from my perspective, more timely or more important to focus on
the issues of jurisdiction in the broadest sense of the word.

In my view, we are at a crossroads in our history today. And I
think the fundamental question facing the Congress and the people
of the United States in this connection is to determine what kinds
of cases it wishes to have heard in the Federal courts.

When we talk of jurisdiction, it is just a fancy way of really an-
swering that question; what kinds of cases belong in the Federal
courts, what kinds of cases belong in the State coordinated systems
of justice?

The Constitution wisely commits to the judgment of Congress the
task to decide the jurisdiction of the Federal courts. And these is-
sues are particularly current and critical today, I think, as we wit-
ness very substantial expansion in the jurisdiction of the Federal
courts, both in the civil area and in the criminal area. Areas that
have been traditionally allocated to the State systems of justice, in-
creasingly are being moved into the Federal system. And so, it
comes, I think, at a particularly appropriate time in our history for
this subcommittee to focus on this question.

The specific proposals at issue today: The one embodied in H.R.
4446 and the second in a suggestion made by the Judicial Con-
ference, share the same basic principle, and that is that in-State
plaintiff diversity jurisdiction generally no longer seems to be a
necessary component of Federal court jurisdiction. Each of the two
proposals, H.R. 4446 and the Conference proposal, would limit or
repeal in-State plaintiff diversity jurisdiction.

A number of reasons, we submit, most respectfully, support this
proposal to either eliminate or to curtail in-State plaintiff diversity
jurisdiction. First, there appears to be no paramount Federal inter-
est in the last decade of the 20th century in providing a Federal
forum for enforcing rights created wholly by State law when the
plaintiff is, indeed, a citizen of the State in which the suit is
brought.

In the second place, the historic reasons which existed in 1789
for congressional establishment of in-State plaintiff diversity juris-
diction; namely, the fear of State court prejudice against creditors,
no longer exists. I do not believe that it can be seriously contended
today that an in-State plaintiff suffers the disability of the
underenforcement of State-created rights in a State forum.

In the third place, these modest proposals, and I think that they
are very limited in their scope to either repeal or to limit the thrust
of in-State plaintiff diversity jurisdiction, are entirely compatible



with the preservation of the balance of general diversity jurisdic-
tion, including the retention of the privilege of removal by an out-
of-State defendant as a protection against whatever perceived local
bias may be thought to exist.

In the fourth place, and I think it was touched on in remarks
made by the chairman, and indeed by Mr. Moorhead already this
morning, the Federal courts are increasingly being challenged to
perform tasks in a changing iurisdictional environment. There is
surely a growing recognition from all quarters that the resources
are limited. Indeed, they are finite.

The nature of the caseload has changed. The volume and the
complexity have changed. Because these resources are so scarce
and so precious, it surely remains the province and the function of
Congress to balance the importance of particular jurisdictional pro-
visions and examine carefully which provisions continue to be vital
to the role of the Federal courts.

In our view, ISP diversity jurisdiction is not essential to the fun-
damental mission of the Federal courts and accordingly should be
either eliminated or limited.

With that, Mr. Chairman, I would be happy to answer any ques-
tions that the subcommittee may have.

[The prepared statement of Judge Marcus follows:]



10



Prepared Statement of Stanley Marcus, Judge Southern
District of Florida, and Chairman, Judicial Conference
Committee on Federal-State Jurisdiction, and Chairman,
Ad Hoc Committee on Gender-Based Violence



Mr. Chairman, I appreciate the opportunity to discuss with the subcommittee your
proposal contained in H.R. 4446, and a similar proposal of the Judicial Conference of the United
States concerning the repeal of in-state plaintiff diversity jurisdiction. I am testifying today in
ray capacity as Chairman of the Judicial Conference Committee on Federal-State Jurisdiction.
These initiatives would correct a long-standing anomaly in the jurisdiction of the federal courts.
That anomaly is generally referred to as "in-state plaintiff" (hereinafter ISP) diversit}'
jurisdiction. In-state plaintiff diversity jurisdiction allows a plaintiff to litigate in federal court
a civil claim based on state law, bypassing the state court system, even when the plaintiff is a
citizen of the state whose court system the plaintiff seeks to avoid. There appears to be no
federal interest in providing a forum for enforcing rights under state law when the plaintiff is
a citizen of the state in which suit is brought. Although the approaches to this issue are slightly
different, we believe they reflect the fundamental view that ISP diversity jurisdiction is no longer
necessary.

Although many people believe today that state courts are unlikely to be prejudiced against
out-o." state litigants, and hence that the general diversity jurisdiction of the federal courts shof'd
be reconsidered, the initiatives under consideration by this subcommittee today are limited in
scope to a discussion of the repeal of ISP diversity jurisdiction. In September of 1993 the
Judicial Conference reaffirmed its position supporting such repeal. These limited proposals are
not linked to or reflective of antagonism to the general principle that federal courts should



11



provide an alternative forum for high-stakes civil cases involving litigants from different states.
The proposals to repeal ISP diversity jurisdiction would have a limited effect on the general
scope of diversity jurisdiction. Furthermore, the anticipated reduction in cases filed would leave
federal courts better equipped to handle those diversity cases in which the party invoking the
right to a federal forum is an outsider to the state court system.

Both H.R. 4446 and the Conference proposal share the idea that ISP diversity jurisdiction
generally is no longer necessary, and the method of approach is similar. H.R. 4446 would
amend 28 U.S.C. § 1332 by adding a new subsection (e) to provide that diversity jurisdiction
may not be invoked if aU plaintiffs in the suit are citizens of the state in which the suit is filed.
The Conference proposal merely extends the elimination of in-state plaintiff diversity jurisdiction
by stating that diversity jurisdiction may not be invoked if any plaintiff is a citizen of that state.
We believe that enactment of either proposal would constitute a significant improvement over
the present system.

IN-STATE PLAINTIFF DIVERSITY JURISDICTION - AN HISTORICAL RELIC
I would like to begin by discussing the history of ISP diversity jurisdiction, which was
first enacted by Congress in 1789 as part of the Judiciary Act's creation of the federal court
system. A review of that history demonstrates that the original justification for ISP diversity
jurisdiction has entirely disappeared.

Since their creation in 1789, the trial courts in the federal system have been vested with
both original and removal jurisdiction over controversies between parties who are citizens of
different states. Congress has never exercised the full scope of its power to grant federal
jurisdiction in diversity cases. The "general" diversity statute, 28 U.S.C. § 1332(a), has always



12

required a minimum dollar amount in controversy and complete diversity of citizenship of all
parties with opposing interests. But despite this measured approach to implementation of
congressional power to confer diversity jurisdiction, one feature of the jurisdiction has remained
constant from 1789 to the present day. While forbidding removal to federal court by an in-state
defendant . Congress has permitted federal diversity jurisdiction to be invoked by an in-state
plaintiff .

Congress had particular reasons in 1789 for providing asymmetrically for access to
general diversity jurisdiction by in-state plaintiffs, but not in-state defendants. The ftmdamental


1 3 4 5 6 7 8 9 10

Online LibraryUnited States. Congress. House. Committee on the JIn-state plaintiff diversity jurisdiction : hearing before the Subcommittee on Intellectual Property and Judicial Administration of the Committee on the Judiciary, House of Representatives, One Hundred Third Congress, second session, on H.R. 4357 (section 305) ... and H.R. 4446 ... May 26, 1994 → online text (page 1 of 10)